No tax so far I think.2) If I convert that partnership interest into shares in a PUBLICLY traded UPREIT I trigger tax on the deemed sale/exchange of the partnership interest into stock of the REIT?

People care more about the appearance of kitchen appliances because they are in a public portion of the house as opposed to washer/dryers which visitors rarely see. 4.

We had to read some IRS publications when we were uncertain about a few things.

However, he is very risk-averse, even more so than myself and the general public.

I 100% agree with the intent aspect and that is an important premise, but the fact is in this particular situation intent for it to be personal use has been confirmed (by way of a public post).

Your question has been debated between BP tax experts both privately and publicly, for example here: https://www.biggerpockets.com/forums/51/topics/819991-expens...And we ended up where we started: no consensus and no clarity.There have also been court decisions that support my interpretation, even though I personally find these court decisions debatable.

Is it public record that I can find online?

But the places we all encounter that could only have a wheelchair ramp put in that intrudes into the public sidewalk (which neither the landlord nor the tenant owns, and now the sidewalk may not be sufficiently wide or accessible for a wheelchair), or that would require tearing down the storefront's façade (envision a storefront right up against the sidewalk), are grandfathered in. 

@Dave Bobka @Justin Arnold So, if an investor is looking for a larger, family style home for a Section 8 tenant that is dependent upon public transit, this would be a great property, wouldn't it?

If you made those free they'd be complaining about jobs or supermarket deserts or lack of public transportation or some other issue.